Contact Form Disclosure Text

DEFINITIONS

In this disclosure text:

• Personal Data: Refers to all kinds of information relating to an identified or identifiable natural person.

• Personal Data Protection Law (“KVKK”): Refers to the Law No. 6698 on the Protection of Personal Data, which was published in the Official Gazette on April 7, 2016, and entered into force on the same date.

• Güven Holding Joint Stock Company (Holding): Refers to the legal entity located at Mutlukent Mah. Gökırmak Sok. No:24 Çankaya / ANKARA.

• Data Processor: Refers to a natural or legal person who processes Personal Data on behalf of the data controller, based on the authority granted by the data controller.

• Data Controller: Refers to a natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

DATA CONTROLLER

Güven Holding Joint Stock Company (hereinafter referred to as the “Holding”) is the Data Controller for the personal data specified in this disclosure text in accordance with Article 3, paragraph 1(ı) of the Law on the Protection of Personal Data No. 6698 (“KVKK”).

Your personal data is processed in accordance with the Law No. 6698 on the Protection of Personal Data and secondary regulations within the purposes and legal bases specified below.
When you fill out the Contact Form available at [https://guvenholding.com/iletisim/], the information you provide — such as Name-Surname, E-mail Address, Phone Number, and Message — is processed by the Holding in accordance with Articles 4, 5, and 6 of the Law for the purposes of establishing communication with you, evaluating and resolving your requests, complaints, and suggestions, in line with the following principles:

• Lawful and fair processing

• Accurate and, where necessary, up-to-date

• Specific, explicit, and legitimate purposes

• Relevant, limited, and proportionate to the purpose for which they are processed

• Retained for the period required by the relevant legislation or for the purpose for which they are processed

WHICH PERSONAL DATA DO WE PROCESS?

Below are the categories of personal data that may be processed by us:

PURPOSE OF PROCESSING PERSONAL DATA

Your personal data described above is processed in accordance with the Personal Data Protection Law and secondary regulations for the following purposes and legal grounds:

• Improvement of Company Activities and Receiving Solution Proposals:
  Based on the legal grounds of “establishment or performance of a contract” under Article 5/2(c) and “legitimate interests” under Article 5/2(f) of the Law, your personal data may be processed to ensure corporate collaboration, evaluate project proposals related to social responsibility and civil society activities, take actions to improve company operations, fulfill your requests, and manage data backup and storage processes.

• Legal Obligations:
  Based on Articles 5/2(a) and 5/2(ç) of the Law (“explicitly provided by law” and “necessary to fulfill the data controller’s legal obligations”), your personal data may be processed to fulfill legal obligations, ensure information security, and maintain the safety of the relationship between parties.

• Dispute Resolution:
  Based on Article 5/2(e) of the Law (“establishment, exercise, or protection of a right”), your personal data may be processed to prove that transactions are conducted lawfully and legal obligations are met, and may be shared with competent legal authorities for dispute resolution.

• Processing of General and Special Categories of Personal Data Related to Requests:
  In the description sections on the website, you are requested to share your personal data only to the extent necessary for your request. Any data shared beyond the scope of your request will be deleted by the Company.

METHODS OF COLLECTING PERSONAL DATA

The Holding collects and processes your personal data primarily through the contact forms available on our website in accordance with the purposes and legal grounds specified in this disclosure text and within the scope of the Law and relevant legislation.

Additionally, your personal data collected through the following channels may also be processed to fulfill your requests:

• Personal data collected through e-mail, verbal communication, call center, written or electronic media, by automated or non-automated means,

• Personal data stored in electronic storage systems, software, accounting programs,

• Personal data collected through communication channels operating on the Internet, such as websites, social media, verbal communications, and SMS.

This disclosure text is prepared for your personal data collected online and processed in connection with such processes.

STORAGE OF YOUR PERSONAL DATA

Your personal data is stored based on one of the data processing conditions set out in Article 5 of the Law and in accordance with the general principles in Article 4 of the Law, particularly for the period prescribed by the relevant legislation or as long as necessary for the purpose for which they are processed. After the retention period expires, the data is destroyed within the appropriate disposal period.

TRANSFER OF PERSONAL DATA

Your collected personal data may be transferred in accordance with the data processing conditions regulated in Articles 8 and 9 of the Law.

• Based on Article 5/2(ç) (“necessary for the fulfillment of the legal obligation of the data controller”), your personal data may be transferred to courts and public authorities for the purpose of fulfilling legal notification obligations.

• Based on Article 5/2(e) (“establishment, exercise, or protection of a right”), your personal data may be transferred to law firms or consultants to serve as evidence in potential disputes or to ensure legal compliance.

• Based on Article 5/2(f) (“legitimate interests of the data controller”), your personal data may be transferred to domestic or foreign suppliers and/or archive companies for secure storage, electronic infrastructure services, or backup systems.

• Based on Article 9/4 (“standard contractual clauses announced by the Personal Data Protection Board ensuring adequate safeguards”), your personal data may be transferred to domestic or international suppliers providing electronic or physical data storage, cloud, or backup services to ensure data security.

RIGHTS OF THE DATA SUBJECT

In accordance with Article 11 of the KVKK, everyone has the right to apply to the data controller and:

1. Learn whether their personal data is being processed,

2. Request information if their personal data has been processed,

3. Learn the purpose of data processing and whether it is used in accordance with that purpose,

4. Know the third parties to whom personal data has been transferred domestically or abroad,

5. Request the correction of personal data if it is incomplete or inaccurate,

6. Request the deletion or destruction of personal data within the framework of Article 7 of the Law,

7. Request notification of actions taken pursuant to (5) and (6) to third parties to whom personal data has been transferred,

8. Object to any unfavorable outcome arising from the analysis of processed data exclusively through automated systems,

9. Request compensation for damages in case of unlawful processing of personal data.

APPLICATION TO THE DATA CONTROLLER

As the data subject, you may submit your requests regarding your rights under Article 13(1) of the Law and in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller (https://www.resmigazete.gov.tr/eskiler/2018/03/20180310-6.htm) in a clear and comprehensible manner, attaching documents verifying your identity and address, in writing and signed, via hand delivery, post, or notary, to the address provided below.
Once your request reaches the Holding, it will be processed as soon as possible and no later than 30 (thirty) days free of charge, depending on its nature. However, if the process incurs a cost, a fee determined by the Personal Data Protection Authority will be charged.

GÜVEN HOLDING JOINT STOCK COMPANY
Address: Mutlukent Mah. Gökırmak Sok. No:24 Çankaya / ANKARA
Phone: +90 312 440 25 40
E-mail: [email protected]
KEP Address: [email protected]